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12. Sony Computer Entertainment America was founded in 1994 and has become a household name in consumer gaming technology. Sony Computer Entertainment America is a Case3:14-cv-03530-JCS Document1 Filed08/05/14 Page3 of 29 57. Class Definition: Plaintiff Douglas Ladore brings this action pursuant to Federal R...
lose
8,187
(Violation of ERISA) (Violation of Collective Bargaining Agreements) 1. Certify the Plaintiff Class and two subclasses under Rule 23 of the Federal Rules of Civil Procedure; 11. Maintenance of this action will promote the efficient administration of justice by obviating the need of numerous individual members,...
lose
386,492
25. Yet in violation of this rule, Defendant fails to obtain any express written consent prior to sending autodialed text messages to consumers, such as Plaintiff. 26. In placing the calls that form the basis of this Complaint, Defendant utilized an automatic telephone dialing system (“ATDS” or “autodialer”) in v...
win
73,667
2.1 guidelines; c. Regularly test user accessibility by blind or vision-impaired persons to ensure that Defendant’s Website complies under the WCAG 2.1 guidelines; and, d. Develop an accessibility policy that is clearly disclosed on Defendant’s Websites, with contact information for users to report accessibil...
lose
439,266
15. Circle K runs a rewards program called “Easy Rewards” to incentive consumers to shop at Circle K, for which it sends unsolicited sign up text messages to consumers. 23. Plaintiff brings this action pursuant to Federal Rule of Civil Procedure 23(b)(2) and Rule 23(b)(3) on behalf of himself and all others simi...
lose
370,719
2. Whether Defendant accepts guide dogs and, if so, if there are any charges associated with the guide dogs, their policies with respect to guide dogs and if there are any rest areas for guide dogs. 25. Defendant owns and operates numerous hotels in the City of New York as well as the rest of the United States. ...
win
231,632
14. In or about February 2001, Joseph Mazzei instituted the Mazzei action against the HomEq Defendants. 15. The Mazzei action arose from the following facts and allegations. Mr. Mazzei took out a mortgage loan with HomEq in 1994. 16. In 1998, Mr. Mazzei fell behind on his mortgage payments and, in 2000, th...
lose
287,424
10. Beginning on or about November 14, 2013, Defendant started placing telephone calls to Plaintiff’s cellular phone ending in 6721. 11. Defendant placed multiple calls for Plaintiff, on her cellular phone, and left her multiple voice-messagesn in the form of pre-recorded messages, asking for a return call at (...
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133,721
(Violation of New York State Human Rights Law, N.Y. Exec. Law, Article 15 (Executive Law § 292 et seq.) (on behalf of Plaintiff and New York subclass) (Violation of New York State Civil Rights Law, NY CLS Civ R, Article 4 (CLS Civ R § 40 et seq.) (on behalf of Plaintiff and New York subclass) (Violation of New...
lose
354,299
28. The number of persons in the class makes joinder of the individual class members impractical. 29. There are questions of fact and law common to all class members. Factually, all class members are public employees and union nonmembers who have been forced to pay “fair-share fees” to the NYSUT as a condition of ...
lose
109,491
37. Mr. Baltierra incorporates the preceding allegations by reference. 38. At all times relevant to this complaint, Orlans Associates sought to collect a "consumer" debt from Mr. Baltierra . 39. Orlans Associates actions to collect this alleged debt from Mr. Baltierra violated the provisions of the FDCPA includin...
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48,077
17. As introduced above, “beacons” are new technologies that seek to track and monitor consumers and how they interact with advertisements and marketing.2 Fundamental to 2 Beacon Technology: The Where, What, Who, How and Why, http://www.forbes.com/sites/homaycotte/2015/09/01/beacon-technology-the-what-who-how- wh...
win
51,682
2.1 guidelines; and, d. Develop an accessibility policy that is clearly disclosed on Defendant’s Websites, with contact information for users to report accessibility-related problems. 2.1 guidelines; c. Regularly test user accessibility by blind or vision-impaired persons to ensure that Defendant’s Website co...
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408,865
52. Plaintiff re-states, re-alleges and incorporates herein by reference, paragraphs one (1) through fifty-one (51) as if set forth fully in this cause of action. 53. This cause of action is brought on behalf of Plaintiff and the members of two classes. 54. Class A consists of all persons whom Defendant’s recor...
win
288,647
48. Defendants intentionally exercised unauthorized dominion and control over funds paid by Kilman and Class to obtain the release of their animals. FOURTH CLAIM – Outrage (as to Kilman only) 50. Morgan acted under color of state law in violating Kilman’s rights under the Fourth, Fifth, and Fourteenth Amendments...
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229,198
(Unjust Enrichment) 11. Upon information and belief, while engaging in these practices, LifePoint routinely seeks payment for the medical bills from those same patients, either directly or indirectly. 12. Upon information and belief, LifePoint seeks payment for medical bills through means that include demanding cash ...
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403,689
19. At all relevant times, Plaintiff had a deposit account with San Diego County Credit Union (the “Account”). 2. Authorization obtained by third party. The account-holding financial institution does not violate the regulation when a third-party payee fails to obtain the authorization in writing or fails to gi...
lose
11,444
27. Within the last four years, Defendant has caused numerous calls with prerecorded messages to be transmitted to Plaintiff’s cellular telephone ending in 8532 (the “8532 Number”), including on or about November 13, 2019 and November 14, 2019. 28. The prerecorded calls at issue were transmitted to Plaintiff’s ...
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42,245
10. Plaintiff had no business relationship with Defendant, did not give Defendant its number, and had not consented to be sent a facsimile. 3 11. No opt out notice was provided as required on all faxes. 12. On information and belief, Defendant continues to send these facsimiles nationwide without prior consen...
win
282,139
19. Whey is a complete protein source, which means it contains all the essential amino acids the human body needs to build protein-based compounds such as muscle tissue, skin, fingernails, hair and enzymes. Daily protein needs depend on one’s size, gender and activity levels, although they likely amount to somewher...
win
329,706
11. Nationwide profited from and received the benefits of marketing of its products and services by fax and is a responsible party under the JFPA. 12. Defendant created or caused to be made Exhibit A hereto, which Defendant knew or should have known advertises Defendant’s goods or products, and Defendant intended...
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327,382
10. Accordingly, on May 2, 2017, Mr. Dugger sent Verizon Wireless a letter, via certified mail demanding that they cease collection of the Verizon debt, which was discharged in Mr. Dugger’s bankruptcy. A copy of this letter is attached as Exhibit F. 11. Plaintiff’s bankruptcy is a matter of public record, is on ...
lose
178,919
14. Gustech relies on Satellite Technicians, such as Plaintiffs, to install and repair DirecTV services and products in states such as North Carolina, South Carolina, Texas, and Florida. 15. Gustech maintains a website which describes its business as installing satellite television in homes. 17. Gustech Tech...
lose
90,897
14. At all times relevant, Plaintiff was a citizen of the State of California. Plaintiff is, and at all times mentioned herein was, “persons” as defined by 43. Plaintiff brings this action on behalf of himself and on behalf of all others similarly situated (“the Class”). 45. GLOBAL and their employees or agents ar...
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37,695
10. Upon information and belief, other similarly situated employees are also uniformly paid in a fashion similar to Plaintiff and not compensated for the expenses associated with performing their job duties. 11. As a matter of economic reality, DoorDash advertises, on the "About Us" section of its website, that ...
lose
66,143
10. Pursuant to the Policy, Plaintiffs paid Auto-Owners an annual premium in exchange for insurance coverage. The required premiums were paid at all times relevant to this Complaint. 11. On or about May 10, 2016, Plaintiffs’ residential buildings located on the Insured Premises suffered hail damage (the “Loss”...
win
244,826
32. Any necessary conditions precedent to the filing of this action occurred or have been waived by Defendant. 33. Plaintiff purchased property by obtaining a mortgage on August 30, 2018 and signing Promissory Note on the same date. 34. Plaintiff stopped paying on the mortgage and note obligations. 35. Subs...
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286,121
2.1 guidelines; c. Regularly test user accessibility by blind or vision-impaired persons to ensure that Defendant’s Website complies under the WCAG 2.1 guidelines; and, d. Develop an accessibility policy that is clearly disclosed on Defendant’s Websites, with contact information for users to report accessibil...
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116,152
25. Defendant operates multiple stores throughout the United States, including its store located at 3015 E 2nd Ave, Denver, CO 80206. 26. Defendant offers its Website in connection with its physical locations. The goods and services offered by Defendant through its Website include but are not limited to the foll...
win
142,293
(Violation of New York State Civil Rights Law, NY CLS Civ R, Article 4 (CLS Civ R § 40 et seq.) (on behalf of Plaintiff and New York Subclass) (Violation of New York City Human Rights Law, N.Y.C. Administrative Code § 8-102, et seq.) (on behalf of Plaintiff and New York Subclass) (Violation of 42 U.S.C. § 12181...
win
208,188
2.0 guidelines; c. Regularly test user accessibility by blind or vision-impaired persons to ensure that Defendant’s Website complies under the WCAG 2.1 guidelines; and, d. Develop an accessibility policy that is clearly disclosed on Defendant’s Websites, with contact information for users to report accessibil...
win
119,356
(Against All Defendants for Violations of Section 14(a) of the Exchange Act and 17 C.F.R. § 244.100 Promulgated Thereunder) (Against All Defendants for Violations of Section 14(a) of the Exchange Act and Rule 14a-9 Promulgated Thereunder) (Against the Individual Defendants for Violations of Section 20(a) of the...
lose
146,909
21. Defendant is a cosmetic and skincare products company that owns and operates the website, www.jouercosmetics.com (its “Website”), offering features which should allow all consumers to access the goods and services which Defendant ensures the delivery of throughout the United States, including New York State. ...
win
47,536
10. Defendant alleges Plaintiff owes a debt (“the Debt”). 11. The Debt was primarily for personal, family or household purposes and is therefore a “debt” as defined by 15 U.S.C. § 1692a(5). 12. Sometime after the incurrence of the Debt, Plaintiff fell behind on payments owed. 13. Thereafter, at an exact ...
win
434,294
(FLSA Overtime Wage Violations) (NJWHL Overtime Wage Violations) 22. Plaintiff commenced his employment with Defendants approximately three (3) years ago. 23. From the commencement of his employment through the termination of his employment on or about June 3, 2018, Plaintiff was paid on an hourly basis. 24...
win
248,540
(Violation of 47 U.S.C. § 227, et seq. – Telephone Consumer Protection Act) (on behalf of Plaintiff and the Class) 11. In an effort to solicit consumers, Defendant sent (or directed to be sent on its behalf) unsolicited text messages, without consent, to cellular telephones while using automatic telephone dialing...
lose
268,633
21. All previous paragraphs are incorporated as though fully set forth herein. 22. Plaintiff brings this FLSA claim as a collective action pursuant to 29 U.S.C. § 216(b) on behalf of all persons in the United States, who, since August 2016, previously worked or currently work for Defendants as home health caregive...
lose
46,907
10. The envelope also provides data symbols similar to a QR code through the glass window of the letter. 11. Courts have repeatedly found such information to directly violate §1692f(8) of the FDCPA which clearly prohibits any language or symbol other than a business name on the outside of an envelope. 12. Pl...
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37,789
15. Plaintiff had residential service with Verizon. 16. Plaintiff advised Verizon that she was moving and ordered that her service be transferred by Verizon to her new address. 17. However, Verizon failed to transfer the services and instead kept the services active at the old address after Plaintiff had mo...
win
17,650
29. Without a brick-and-mortar store, most online payday and other predatory lenders rely heavily on marketing and advertising to prey on consumers.^ 31. Lead generators pay high fees to several sources to acquire borrower information, including consumer reporting agencies. Often, lead generators use a non-Big 3^ cons...
lose
77,738
27. Plaintiff brings this action on behalf of himself and on behalf of and Class Members of the proposed Class pursuant to Federal Rules of Civil Procedure 23(a) and (b)(3) and/or (b)(2). 39. Plaintiff incorporates by reference all of the above paragraphs of this Complaint as though fully stated herein. 40. D...
win
366,776
22. Plaintiff brings this action pursuant to Federal Rule of Civil Procedure 23(b)(2) and Rule 23(b)(3) on behalf of himself and all others similarly situated and seeks certification of the following Class: Autodialed No Consent Class: All persons in the United States who from four years prior to the filing of thi...
lose
50,147
(FLSA: Unpaid Minimum Wage) (FLSA: Failure to Pay Overtime Compensation) (NYLL: Unpaid Minimum Wage) (NYLL: Unlawful Deductions) (NYLL: Failure to Pay Overtime Compensation) (NYLL: Failure to Furnish Wage Statements) (On Behalf of Plaintiff Silva) (NYLL: Retaliation) 10. Plaintiffs bring this action on ...
win
389,452
13. Texts sent by or on behalf of Nations Info are solicitations for Nations Info’s rent- to-own membership services. 48. Plaintiff brings this action pursuant to Federal Rule of Civil Procedure 23(b)(2) and Rule 23(b)(3) on behalf of herself and all others similarly situated and seeks certification of the follo...
lose
372,025
11. Plaintiff brings this claim on behalf of the following case, pursuant to Fed. R. Civ. P. 23(a) and 23(b)(3). 13. The identities of all class members are readily ascertainable from the records of Defendants and those companies and entities on whose behalf they attempt to collect and/or have purchased debts. ...
win
442,225
14. Thom Browne owns and operates stores throughout the United States, including a location at 100 Hudson Street, New York, New York. It sells, at these stores, shirts, pants, jackets, eyewear, shoes, accessories and similar items. 15. Thom Browne’s Website is heavily integrated with its stores, serving as a gat...
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417,808
19. The Plaintiff, on behalf of himself and all others similarly situated, seeks to certify a New York City subclass under Fed. R. Civ. P. 23(a) and 23(b)(2): all legally blind persons in the City of New York who have attempted to access the Defendant’s website and as a result have been denied access to the equal en...
lose
157,986
2.0 guidelines; c. Regularly test user accessibility by blind or vision-impaired persons to ensure that Defendant’s Website complies under the WCAG 2.0 guidelines; and, d. Develop an accessibility policy that is clearly disclosed on Defendant’s Websites, with contact information for users to report accessibil...
lose
1,571
(FLSA Overtime Violations) (Ohio Overtime Violations) (Violations of Ohio Revised Code 4113.15) 12. At all times relevant, Defendant was an “employer” within the meaning of the FLSA, 29 U.S.C. § 203(d). 13. Defendant’s hourly employees included Plaintiff and the Opt-Ins. 14. At all times relevant, Defend...
lose
135,987
10. Since at least 2018, Defendants have engaged in a practice of leaving repeated, unsolicited, prerecorded messages on the cellular telephone voicemails of individuals who own property in Arizona. 11. Defendants’ telemarketing calls are not initiated or monitored by a live person. 13. The voicemail message...
lose
444,411
&_Arvairik, Fulton County Superior Court ***EFILED*'"IVV Date: 4/13/2017 9:10:15 AM X Cathelene Robinson, Clerk tlher -Tyier on -)(11-1- Off' [•,ve am," Lmoirvl,c-; DWaYli./ Plaintiff VS. 1-,_Yr(1 I (d/b/ 4 ' 4'v-ectt "3. alper Fred -J -py) youtt.i) t and_ 'Opf.J..S 136 PRYOR STREET, ROOM C-103, ATLANTA, GEORGIA 3...
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439,230
(FLSA – COLLECTIVE ACTION FOR UNPAID OVERTIME) (O.R.C. § 4111.03 – RULE 23 CLASS ACTION FOR UNPAID OVERTIME) (R.C. § 4113.5 – RULE 23 CLASS ACTION FOR VIOLATIONS OF THE OHIO PROMPT PAY ACT) 23. At all times relevant herein, Plaintiff was jointly employed by Defendants as an STNA from approximately May 2017 whe...
win
350,378
20. RCS is a nationwide staffing firm that provides services to the energy, engineering, and utility sectors. 21. In order to provide these services, it employs individuals like Weller. 22. Weller was an hourly employee of RCS. 23. Weller was hired around August of 2016. 63. RCS’s illegal “straight tim...
win
338,657
10. Discovery may reveal the transmission of additional faxes as well. 11. Defendant Locums, Inc., is responsible for sending or causing the sending of the faxes. 13. Defendant Locums, Inc., either negligently or wilfully violated the rights of Plaintiff and other recipients in sending the faxes. 14. Each fax refer...
win
401,281
14. Plaintiff brings this action on behalf of himself and all others similarly situated, as a member of the proposed class (hereafter “The Class”) defined as follows: All persons within the United States who received any telephone calls from Defendant or Defendant’s agent/s and/or employee/s to said person’s cellular t...
lose
313,306
33. Defendant owns, manages and/or operates hotels throughout the United States. 34. As a fundamental part of these operations, Defendant provides hotel rooms with sleeping beds to its customers. 35. Within the applicable limitations period, Plaintiff called the Courtyard by Marriott located in Coraopolis, P...
lose
46,935
32. Advertising to cellular phones uses the called party’s equipment. 33. Lower Insurance Rates transmitted autodialed and prerecorded calls to cellular phones—those of Plaintiff and the other members of the putative Class— to promote Direct Auto Insurance’s products and services without the called parties’ prio...
win
153,152
42. By investing or keeping invested funds in Plaintiffs' retirement accounts for purposes other than their benefit after receiving their written transfer requests, TIAA-CREF exercised authority or control respecting the management or disposition of such accounts and must be deemed a fiduciary under section 3(21)(A...
win
235,705
32. Plaintiff brings this action as a class action pursuant to Rule 23 of the Federal Rules of Civil Procedure on behalf of all persons who purchased or otherwise acquired Imperva publicly traded securities during the Class Period (the “Class”). Excluded from the Class are defendants and their families, the office...
win
26,306
16. Defendants provide oil and gas well monitoring services to energy companies nationwide. 17. Defendants employ their workforce to monitor and maintain oil and gas wells in multiple states including Texas, Oklahoma, Colorado, Pennsylvania and North Dakota. 19. Plaintiff and Class Members are employed by Defendants ...
win
201,753
60. This action is brought as a class action. Plaintiff brings this action on behalf of herself and on behalf of all other persons similarly situated pursuant to Rule 23 of the Federal Rules of Civil Procedure. 61. The identities of all class members are readily ascertainable from the records F.H. Cann & Associa...
win
50,953
10. Defendant used an “automatic telephone dialing system”, as defined by 47 U.S.C. § 227(a)(1) to place its call to Plaintiff seeking to solicit its services. 11. Defendant contacted or attempted to contact Plaintiff from telephone numbers (310) 219-3150 and (619) 543-8187. 12. Plaintiff requested Defendan...
lose
99,932
10. Defendant contacted Plaintiff between on or around December of 2016 in an effort to solicit its business. 11. Defendant’s messages constituted “telephone solicitation” as defined by the TCPA, 47 U.S.C. § 227(a)(4) and “unsolicited advertisement” as defined by the TCPA, 47 U.S.C. § 227(a)(5). 12. Defendant...
lose
14,072
23. Defendant is a women’s fashion boutique and clothing retailer. Defendant is an online retailer of women's clothing, footwear, jewelry, and other accessories, carrying popular brands such as Adidas, Champion, and I.AM.GIA, as well as Defendant’s own private labels.. Defendant owns, operates, manages, and control...
lose
134,150
14. Defendant is an online retailer of CBD products. Products available for purchase on its Website include apparel, salves, honey, and tincutres (concentrated herbal extracts) for men, women, and pets. 15. Defendant’s Website is heavily integrated with its retail operation, serving as its gateway. Through th...
win
140,671
12. Plaintiff Houck attended Georgetown University Law Center, where she was an Editor on the Georgetown Journal on Poverty Law & Policy.7 After graduation in 2011, Plaintiff Houck passed the bar exam and was sworn into the California Bar later that same year. 13. Plaintiff Houck joined Steptoe & Johnson on May 1, 201...
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48,388
10. Unfortunately, many of the people whose cell phones were called as a result of Defendant’s autodialing and artificial or prerecorded voice message practices never actually consented to receive such calls. 11. On information and belief, many of these individuals were called more than once, and Defendant lacks...
win
288,938
10. In or about May of 2013, Plaintiff went to Wal-Mart and purchased a Bell+Howell-trademarked electronic/ultrasonic pest control device manufactured and marketed by Defendant in order to expel these pests from her house. 11. Defendant BHH licenses the Bell+Howell trademark to Van Hauser and EMSON for the purp...
lose
242,198
2018CH15633 Brenda Mason ("Plaintiff'') files this Class Action Complaint against Heartland Employment Services, LLC ("Defendant") for violations of the Illinois Biometric Information Privacy Act. 24. When Plaintiff scanned her fingerprint in Defendant's biometric time clock, her fingerprint- or a geometric repre...
win
26,065
34. In or about November 2013 Defendants hired Plaintiff to work as a non-exempt employee at one of the locations of the chain of mobile telecommunications store Defendants own and operate. 35. Plaintiff at all relevant times was a covered employee within the meaning of the FLSA and NYLL. 36. For the first ...
win
252,795
2.0 guidelines; c. Regularly test user accessibility by blind or vision-impaired persons to ensure that Defendant’s Website complies under the WCAG 2.0 guidelines; and, d. Develop an accessibility policy that is clearly disclosed on Defendant’s Websites, with contact information for users to report accessibil...
lose
179,641
42. Proposed Class Definition: Plaintiff Calderon brings this action pursuant to Federal Rules of Civil Procedure 23(b)(2) and 23(b)(3) on behalf of a class of similarly situated individuals, defined as follows (the “Class”): All Google Photos users located in Illinois for whom Google created and stored a face te...
lose
354,502
11. Upon information and belief, Defendant develops marketing campaigns using a combination of sales channels, with an emphasis on outbound telemarketing. 12. Upon information and belief, Defendant utilizes third party vendors to market its services. 13. Upon information and belief, Defendant’s vendors are ess...
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205,853
43. On May 28, 2020, days after George Floyd’s death, protests began across New York City. One protest in Union Square saw a mobilization of hundreds of NYPD officers in response who made several arrests. A group of protestors marched to City Hall where officers kettled them with bicycles, and arrested approximatel...
lose
450,179
(Declaratory Relief) (Disability Discrimination in Violations of NYC Human Rights Law § 8-107(4)) (Injunctive Relief and Damages on Behalf of Plaintiffs) (Failure to Reasonably Accommodate in violation of NYC Human Rights Law § 8-107(15)) (Injunctive Relief and Damages on Behalf of Plaintiffs) (Violations of N...
win
273,072
45. Arc provides weld inspection services to the oilfield and other industries. 46. Malone began working for Arc in January 2018. 47. Howard began working for Arc in July 2018. 48. Kinworthy began working for Arc in September 2018 49. Malone, Howard, and Kinworthy were employed as inspectors/radiographers ...
win
287,070
14. Defendant JPMorgan Chase Bank, N.A. is a national banking association that “is one of the oldest financial institutions in the United States.” Defendant is a “leader in investment banking, financial services for consumers and small businesses, commercial banking, financial transaction processing and asset manag...
win
392,094
10. The Single Phone Report search provided Plaintiff the option of making a regular purchase, or obtaining a special offer price of $0.95 to purchase the Single Phone Report by signing up for a Spokeo trial membership. 11. Plaintiff selected the Single Phone Report with Spokeo trial membership, and was then t...
lose
406,784
22. All Plaintiffs performed substantially similar duties. 23. Plaintiffs at all relevant times were covered employees within the meaning of the FLSA and NYLL. 24. Plaintiff Castro’s employment began in or about 2008. He was and continues to be employed as a busboy. 25. Plaintiff Castro’s regular work sch...
win
91,723
27. Defendant offers the commercial website, WWW.JERSEYSHOREPOWERSPORTS.COM, to the public. The website offers features which should allow all consumers to access the products and services which Defendant offers in connection with their physical locations. The products and services offered by Defendant include...
win
47,675
10. Plaintiff alleges that at all times relevant herein Defendant conducted business in, and is incorporated in San Jose, California, within this judicial district. 11. On February 3, 2016, Plaintiff received an e-mail from Defendant informing Plaintiff that Defendant needed Plaintiff’s help resolving an alleged i...
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2,492
(Class Claims Under New York General Business Law §349) (Plaintiff Individually-Breach of Contract)) (Plaintiff Individually- Bad Faith Claims) 10. Prior to September 2011, Plaintiff purchased an automobile liability insurance policy No. 012852471C71017 (the “Policy”) from USAA in New York, which in pertinent ...
lose
318,205
20. EVHC conducts background checks, which include investigations of criminal history, of its job applicants as part of its standard screening and hiring process. 21. In addition, EVHC periodically conducts such background checks on existing employees during the course of their employment with EVHC. 22. EVHC d...
win
84,176
(Against the Sales Defendants) (Against Bioceutica) (Against the Sales Defendants) 29. Plaintiff brings this class action for Defendants’ violations of the TCPA and GBL 399-p on behalf of himself and all others similarly situated under rule 23(a) and 23(b)(1)- 23(b)(3) of the Federal Rules of Civil Procedure. ...
lose
413,690
10. Bulk text messaging has become a popular means by which companies can directly communicate with cell phone owners for the purpose of soliciting business. 11. Short Messaging Service, or “SMS” is a cellular telephone messaging system that allows the cellular telephone subscribers to use their cellular devices ...
lose
441,460
( Overtime Wages Under the FLSA) (Overtime Under the NYLL) (Unpaid Wages Under the NYLL) 15. At all time relevant, each Plaintiff was hired and employed by Defendant within the City and State of New York and worked primarily in Richmond County. 16. Plaintiffs have worked for Defendant to provide superviso...
lose
146,388
10. Defendant contacted or attempted to contact Plaintiff from multiple telephone numbers. 11. Defendant’s calls constituted calls that were not for emergency purposes as defined by 47 U.S.C. § 227(b)(1)(A). 12. Defendant’s calls were placed to telephone number assigned to a cellular telephone service for whi...
win
44,095
(FLSA – COLLECTIVE ACTION FOR UNPAID OVERTIME) (R.C. § 4113.5 – RULE 23 CLASS ACTION FOR VIOLATIONS OF THE OHIO PROMPT PAY ACT) (R.C. § 4111.03 – RULE 23 CLASS ACTION FOR UNPAID OVERTIME) 23. All of the preceding paragraphs are realleged as if fully rewritten herein. 24. During his employment with Defendants...
win
342,518
10. On December 9, 2009, Defendants filed a foreclosure lawsuit in Cook County court against Plaintiff, Case No. 09 CH 49203. In June 2010, F&S filed an Affidavit of Prove- Up Pursuant to 735 ILCS 5/15-1506 (“Affidavit”), contemporaneously with motions for judgment and default, in that lawsuit. 11. The Affidav...
win
439,022
40. Plaintiff repeats, reiterates and incorporates the allegations contained in paragraphs above herein with the same force and effect as if the same were set forth at length herein. 41. Defendant is a debt collector as defined by the FDCPA. See 15 U.S.C. § 1692a(6). 42. Plaintiff is a consumer as defined by t...
win
301,235
14. Plaintiff and the members of the Class are present and former patients of CCP. 15. As a condition for receiving treatment, Plaintiff and Class members were required by CCP to confide and make available to it, its agents, and its employees, sensitive and confidential PII, including, but not limited to, their ...
lose
72,524
25. Plaintiff incorporates by reference and re-alleges each and every paragraph above as though fully alleged herein. 26. Plaintiff and each Class Member entered into a Membership Agreement with Massage Envy and/or Massage Envy’s franchisee clinics. 27. Plaintiff and each Class Member obliged by the Membership...
win
147,642
10. Attorneys routinely contact their clients in both TCJ and TCCC by phone or videoconference to discuss confidential matters. They do so with the understanding their conversations are private. Similarly, inmates understand remote conversations with their attorneys are confidential and not recorded. 11. TCJ and T...
win
445,376
(Fair Labor Standards Act - Unpaid Overtime) (NJWHL/NJWPL- Unpaid Overtime) 30. The claims in this Complaint arising out of the FLSA, New Jersey Wage and Hour Law and New Jersey Wage and Payment Law are brought by Plaintiff under Rule 23 of the Federal Rules of Civil Procedure, on behalf of himself and of a cla...
win
302,457
21. Defendant is a beauty products company that owns and operates the website, www.hudabeauty.com (its “Website”), offering features which should allow all consumers to access the goods and services which Defendant ensures the delivery of throughout the United States, including New York State. 22. Defendant’s We...
lose
435,946
10. This Court has jurisdiction pursuant to 28 U.S.C. § 1331 as this case is brought pursuant to The Fair Labor Standards Act, 29 U.S.C. §§ 201-219 (section #216 for jurisdictional placement). 12. Plaintiff worked for Defendant as pool installer and concrete worker from on or about November 20, 2016 through to on...
win
74,594
10. Defendant contacted or attempted to contact Plaintiff from telephone number 503-468-5336. 11. Defendant’s calls constituted calls that were not for emergency purposes as defined by 47 U.S.C. § 227(b)(1)(A). 12. During all relevant times, Defendant did not possess Plaintiff’s “prior express consent” to receive c...
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223,851
11. In or around May 2011 through December 2011, Plaintiff Frank Ortega purchased Cobra from CVS in Reseda, Los Angeles County, California and from Rite- Aid and Target stores located in Northridge, California. The cost was approximately $16- $17 per bottle. 12. Mr. Ortega first discovered Defendants’ unlawful act...
win
70,453
39. Mr. Brown adopts by reference the contents of the preceding paragraphs as if fully set forth herein. 40. Barring oral requests for money now but not regulating requests for money later as the panhandling statute does is a form of content discrimination. 41. The panhandling statute therefore violates the Fi...
lose
23,648
11. Plaintiffs purchased a single-family home in San Marcos, California, with the transaction closing on or about October 19, 2018. 12. At around the same time and in connection with their purchase, Plaintiffs entered into a mortgage loan agreement with lender loanDepot.com, LLC (the “2018 Mortgage”). That loan...
lose